On January 19, 2021 the US Department of the Treasury’s Office of Foreign Assets Control announced additional designations related to the illegitimate Maduro regime’s continued efforts to evade US sanctions while supporting Venezuela’s oil sector. Toward this end, three individuals, fourteen entities, and six vessels were designated by OFAC pursuant to Executive Order 13850, as amended, targeting participants with ties to Maduro’s oil minister, Tareck El Aissami Maddah, and indicted money launderer Alex Nain Saab Moran, who brokered the sale of hundreds of millions of dollars of Venezuelan oil.
The principal actors designated by OFAC include Alessandro Bazzoni, Francisco Javier D’Agostino Casado, Philipp Paul Vartan Apikian, and entities Elemento Ltd and Swissoil Trading SA that is owned by Apikian. These five were designated for operating in Venezuela’s oil sector and providing material or financial support to Petroleos de Venezuela, S.A. (PdVSA), Venezuela’s state owned oil and gas company that was designated in 2019. Nine of the sanctioned entities are owned or controlled by Bazzoni, D’Agostina, or Elemento, and were designated for being owned or controlled by blocked persons. Finally, three maritime entities were designated for operating in Venezuela’s oil sector and six vessels were identified as blocked property of these entities.
As a result of these designations, all interests in US property is blocked and all transactions are generally prohibited. In addition, any entity that is owned 50 percent or more by a designated person or entity is also blocked.